Williams v. Smith

CourtCourt of Appeals for the Second Circuit
DecidedApril 17, 2026
Docket24-2733
StatusUnpublished

This text of Williams v. Smith (Williams v. Smith) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. Smith, (2d Cir. 2026).

Opinion

24-2733 Williams v. Smith

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 17th day of April, two thousand twenty-six.

PRESENT:

ROBERT D. SACK, RICHARD J. SULLIVAN, EUNICE C. LEE, Circuit Judges. _____________________________________

STEPHEN J. WILLIAMS,

Plaintiff-Appellant,

v. No. 24-2733

DARYL NORVAL SMITH, in his individual capacity and in his capacity as a representative for the FAA administrator, FEDERAL AVIATION ADMINISTRATION, an agency of the United States Federal government, NICHOLAS ALBERT EULL, in his capacity as manager of the FAA Bradley Flight Standards District Office, MICHAEL GORDON WHITAKER, THE DEPARTMENT OF MOTOR VEHICLES, an agency of the State of Connecticut, ANTONIO TONY GUERRERA, in his capacity as the Commissioner of Motor Vehicles, ANTHONY FAMIGLIETTI, in his capacity as legal counsel for the Department of Motor Vehicles, EILEEN MESKILL, in her capacity as legal counsel for the Department of Motor Vehicles, RONALD DANTE FONTENOT, in his capacity as the acting manager of the FAA Specialty Aircraft Examiner Branch, JANE DOES, AND VARIOUS UNKNOWN, in their capacity as employees of the Department of Motor Vehicles, JOHN DOES, AND VARIOUS UNKNOWN, in their capacity as employees of the Department of Motor Vehicles, JANE DOES, VARIOUS UNKNOWN, in their capacity as employees of the Federal Aviation Administration, JOHN DOES, VARIOUS UNKNOWN, in their capacity as employees of the Federal Aviation Administration,

Defendants-Appellees,

JASON AUBREY GEORGE, in his capacity as manager of the FAA Bradley Flight Standards District Office, now retired, BILLY JOE NOLEN, in his capacity as the acting administrator of the FAA, CAROL CECCONE CARPENTER, in her individual capacity as partner operating under the registered Missouri fictitious name Rainbow Aviation Services, BRIAN JOHN CARPENTER, in his individual capacity as partner operating under the registered Missouri fictitious name Rainbow Aviation Services,

2 Defendants. _____________________________________

For Plaintiff-Appellant: STEPHEN J. WILLIAMS, pro se, Storrs, CT.

For Connecticut Defendants- BRIAN E. TETREAULT, Connecticut Office of Appellees: the Attorney General, Hartford, CT.

For Federal Defendants- JOHN W. LARSON (Elena Lalli Coronado, on Appellees: the brief), Assistant United States Attorneys, for David X. Sullivan, United States Attorney for the District of Connecticut, New Haven, CT.

Appeal from a judgment of the United States District Court for the District

of Connecticut (Sarala V. Nagala, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the August 12, 2024 judgment of the district

court is AFFIRMED.

Stephen J. Williams, an attorney proceeding pro se, appeals from the district

court’s judgment dismissing his claims against (i) the Federal Aviation

Administration (“FAA”) and various FAA officials (collectively, the “Federal

Defendants”) for allegedly violating the Administrative Procedure Act (“APA”),

5 U.S.C. § 555(b), when they delayed the scheduling of his flight-instructor exam,

and (ii) the Connecticut Department of Motor Vehicles (“DMV”) and various

DMV officials (collectively, the “Connecticut Defendants”) for allegedly violating

3 his constitutional rights when they suspended his driver’s license for non-

payment of a speeding ticket. On appeal, Williams argues that the district court

erred in concluding that (i) the FAA’s legal interpretation regarding licenses for

flight-simulator instructors was an interpretive rule exempt from notice-and-

comment rulemaking; (ii) the FAA’s delay in scheduling his exam was reasonable;

and (iii) Connecticut’s suspension of his driver’s license for failure to pay the fine

on a speeding ticket comported with due process. We assume the parties’

familiarity with the underlying facts, procedural history, and issues on appeal, to

which we refer only as necessary to explain our decision.

“We review de novo a district court’s grant of a motion to dismiss, accepting

as true all factual allegations in the complaint and drawing all reasonable

inferences in favor of the plaintiff[].” Muto v. CBS Corp., 668 F.3d 53, 56 (2d Cir.

2012). Although we “ordinarily . . . afford a special solicitude to pro se litigants,”

“a lawyer representing himself” – like Williams – will generally “receive[] no such

solicitude at all.” Tracy v. Freshwater, 623 F.3d 90, 101–02 (2d Cir. 2010).

For substantially the reasons identified by the district court, we affirm. First,

we agree with the district court that the FAA’s legal interpretation – issued as a

letter from Rebecca B. MacPherson, Assistant Chief Counsel for Regulation, to

4 Stephen Gatlin, see 2010 WL 3827463 (Sept. 24, 2010) – was at most an interpretive

rule, not a legislative rule, and was therefore not subject to the “notice[-]and[-]

comment provisions of the APA,” Sweet v. Sheahan, 235 F.3d 80, 90 (2d Cir. 2000);

see also 5 U.S.C. § 553(b)(A). “[L]egislative rules are those that create new law,

rights, or duties, in what amounts to a legislative act”; by contrast, “[i]nterpretive

rules . . . do not create rights, but merely clarify an existing statute or regulation.”

Id. at 91 (internal quotation marks omitted). Because the legal interpretation here

was merely the FAA’s response to an individual’s question regarding the meaning

of a particular term in a preexisting FAA regulation, it by no means “create[d] new

law, rights, or duties.” Id. (internal quotation marks omitted).

Second, we agree with the district court that, at the time of its decision,

Williams’s unreasonable-delay claim was not ripe because he no longer met the

prerequisites for his flight-instructor exam. As a result, Williams lacked Article III

standing. See Nat’l Org. for Marriage, Inc. v. Walsh, 714 F.3d 682, 688 (2d Cir. 2013)

(explaining that ripeness relates to the first prong of the standing inquiry and

requiring a plaintiff’s injury to be “actual or imminent,” and not merely

“conjectural or hypothetical” (internal quotation marks omitted)). To be sure,

Williams had met two prerequisites for certification – possessing a current logbook

5 endorsement and a current knowledge-test report – when he first filed suit; but

those documents had expired by the time the district court ruled on the Federal

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Related

Tracy v. Freshwater
623 F.3d 90 (Second Circuit, 2010)
Muto v. CBS Corp.
668 F.3d 53 (Second Circuit, 2012)
Gudema v. Nassau County
163 F.3d 717 (Second Circuit, 1998)
National Organization for Marriage, Inc. v. Walsh
714 F.3d 682 (Second Circuit, 2013)
Village of Willowbrook v. Olech
528 U.S. 562 (Supreme Court, 2000)
Deshawn E. ex rel. Charlotte E. v. Safir
156 F.3d 340 (Second Circuit, 1998)
Sweet v. Sheahan
235 F.3d 80 (Second Circuit, 2000)

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Williams v. Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-smith-ca2-2026.